Audits happen for companies operating commercial motor vehicles daily. Here is everything you need to know about audits and how to prepare for when the auditor comes around.
When your company is notified of a DOT Compliance Audit, the best thing that you can do is to be prepared. Now, there are many different things you can do to get your company prepared for a DOT Audit but the best practice is to be as organized as possible and keep all relevant documentation readily available for the auditor. The more prepared you are, the smoother the audit process will go.
Remember, the auditor is there to learn about your business and no matter how friendly they may seem they aren't there to do you a favor. Get the auditor everything they need and keep them away from the general business areas.
The files you submit to the auditor should have a limited amount of information, no more and no less than what they need or request to see.
As your company is audited, be sure to ask questions if you have them. Before the auditor leaves, make sure you understand everything that will be in the final report. If you believe that the auditor has made false findings, you are able to challenging them at this time.
What Happens During a DOT Audit?
Throughout the process of the audit, the auditors look for patterns and consistency in violations, abuse, or ongoing safety issues - such as speeding tickets. This gives them a better understanding of the situation and allows the auditor to properly assess the situation.
DOT audits are primarily conducted through various documents. It is important to know what to expect and how to prepare for such an audit.
Below is the lists of items you must review to ensure a successful DOT audit. The auditors will demand documentation and information from these three key categories: drivers, vehicles, and the carrier.
It is of the utmost importance to ensure each item within these categories is properly maintained to avoid a failure in your audit and thereby meet the requirements to safeguard the future of your business.
Drivers
Here's the information you need to get on each of your drivers:
Driver Information:
Name, date of hire, license number, and date of birth.
Driver’s licenses:
All drivers must have an active commercial driver’s license (CDL). You will need to make note any driver exemptions.
Records of duty (ROD):
RODs provide detailed documentation of an employee's hours of service (HOS) and other relevant information. This allows employers to track employee HOS and ensure compliance with labor laws and regulations laid out by the FMCSA.
Motor vehicle records (MVR):
You are required to run your drivers' MVRs every year, keep the MVRs on file for three years.
Driver’s safety performance history:
If you have been recording your driver's safety performance history, three years per driver will be the most beneficiary. If you aren't already doing this, we highly recommend it.
Certificate of violations:
The drivers must provide documentation of any violations they have received in the past 12 months.
Medical certificate:
Documentation of physical examination from a certified medical examiner every two years while employed.
Application for employment:
Outlining an employee's work history, accidents, background, and reasons for leaving previous employers.
Road test and driver training:
Indicates that each driver has successfully completed a driving skills evaluation test.
After reviewing all relevant records and documentation related to drivers, auditors may also request to see additional HOS logs for specific drivers who have been involved in accidents or have had violations.
Vehicles
The auditor will need to review documents regarding your company's vehicles used for business purposes, to include:
Vehicle list:
A list of all vehicles in your fleet, their corresponding unit, plate numbers, and the vehicle identification number.
Proof of vehicle inspections:
ALL documentation of a passed vehicle inspection within the last year.
Proper vehicle markings:
Your business name and USDOT number should be visible on both sides of every vehicle in your fleet.
Hazmat shipping documents:
All shipping documents and contact information for drivers transporting hazardous materials, need to be filed and maintain these records for 1-3 years.
Carrier
These are the company/carrier documents you will need for your DOT audit.
Proof of insurance:
Carriers must provide proof of insurance, the minimum amount depends on the types of shipments your company is hauling.
Accident register:
You are required to keep and maintain an accident register, if your company is involved in an accident that record must be kept for three years.
Drug and alcohol program:
You are required to provide documentation of your drug and alcohol testing program and pre-employment tests if you have CDL drivers. The pre-employment tests can be done through the FMCSA Clearinghouse. You must also demonstrate that your company is performing randomized drug and alcohol tests that comply with FMCSA regulations.
If you do not have a drug and alcohol program, please click the link below and we will help you start the proper program for your company.
Summary
It is imperative to do everything you can to be and stay in compliance. Below are some violations that can result in an immediate audit failure. Keep these in mind before your audit to ensure you are prepared.
Driver has a failed medical exam, not allowed to operate a commercial vehicle.
If your company does not have sufficient proof of an alcohol and drug testing program, or they are not following the law and putting other people at risk.
If a driver refuses a drug or alcohol test or doesn’t follow up with failed tests, they are not fit to drive and shouldn't be operating in safety sensitive functions.
Failure to maintain adequate HOS documentation.
Operating a vehicle without the minimum insurance coverage required.
Operating vehicles that have not undergone proper inspections.
What are the Consequences of Failing a DOT Audit?
After a DOT audit, you may receive one of three marks: satisfactory, conditional, or unsatisfactory.
A Satisfactory Mark does not mean you can relax.
This means that the auditor found you are following the important requirements and regulations of the DOT. This doesn't mean you'll never have a an audit again, if your CSA score goes up, you receive an inordinate number of customer complaints, or one of your vehicles is involved in a high-profile crash, you may be subject to another DOT Audit. A Conditional Mark This means that your company has not complied with certain aspects of the audit, but is not considered to be a safety risk. This could result in costly DOT audit fines, and potentially even increase your insurance. However, by filing a Safety Management Plan it is possible to bring yourself back up to satisfactory from the conditional rating.
An Unsatisfactory Rating is a Problem. This means that you have been found in violation of federal safety regulations by the DOT auditor. This will definitely result in fines, depending on the severity of the situation, your business may be put "out of service." If you receive an unsatisfactory rating, you do have the opportunity to submit a Safety Management Plan just like with conditional marks. This must be submitted within 45-days to submit a plan if you are a passenger or hazmat company, and 60-days if you operate another CMV business.
If you would like to learn more about what to expect from an audit, click the link below.
Regardless if you've been keeping up with your record keeping and following all the rules and regulations laid out by the FMCSA, it is human instinct to be nervous as the audit approaches. It cannot be overstated how important it is to be prepared, especially if your company does not operate specifically as a trucking company, but uses trucks to transport property across interstate lines.
When you are notified of an impending audit, call Front Range Compliance Services to help you get fully prepared and assist you on the day of the audit. We are DOT Audit Specialists, looking to help you to the best of our ability.
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Until then, make sure to check out our online DOT Training platform, DOT University! We currently are offering Reasonable Suspicion for Supervisors, Cargo Securement, Defensive Driving, and Pre/Post Trip Inspection. In the coming months we plan on releasing Designated Employer Representative and Appendix A.
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